– Policy owner: Compliance Lead
– Approved by: Educato Limited Management
– Version: 2.1
– Effective date: June 2026
– Review date: June 2027
Educato Limited
Company number: 16266179
Registered office: Mentor House, Ainsworth Street, Blackburn, BB1 6AY
Telephone: 0161 804 8860
Email: info@educato.co.uk
Website: www.educato.co.uk
Educato Limited is committed to preventing modern slavery, human trafficking, forced labour, servitude and all forms of labour exploitation within its business operations and supply chains.
As an education recruitment business, we recognise our responsibility to protect workers, candidates, employees and supply chain partners from exploitation and abuse and to act ethically, transparently and responsibly in all business activities.
Educato Limited adopts a zero‑tolerance approach to modern slavery and human trafficking. We are committed to:
– Complying with the Modern Slavery Act 2015 and relevant employment legislation.
– Promoting ethical recruitment and safer‑recruitment practices in line with education sector standards.
– Protecting workers from exploitation and ensuring all work is undertaken voluntarily.
– Maintaining robust right to work and identity verification procedures.
– Supporting vulnerable individuals and responding appropriately to concerns.
– Investigating all reports of suspected exploitation and taking proportionate action.
We will not knowingly engage with individuals, suppliers or organisations involved in modern slavery or human trafficking.
Although Educato Limited is below the statutory turnover threshold requiring a modern slavery statement to be published under section 54 of the Modern Slavery Act 2015, we choose to publish this policy as a matter of good practice and transparency.
This policy applies to all individuals and organisations connected with Educato Limited, including:
– Directors and employees.
– Recruitment consultants and compliance personnel.
– Agency workers and candidates.
– Contractors, umbrella companies and payroll providers.
– Suppliers and third‑party service providers.
It applies across all aspects of our operations and supply chains.
This policy has been developed with reference to:
– Modern Slavery Act 2015.
– Employment Agencies Act 1973.
– Conduct of Employment Agencies and Employment Businesses Regulations 2003.
– Immigration, Asylum and Nationality Act 2006.
– National Minimum Wage Act 1998.
– Equality Act 2010.
– Data Protection Act 2018 and UK GDPR.
– Keeping Children Safe in Education 2025.
– REC Code of Professional Practice and REC Audited Education Standards.
Modern slavery is an umbrella term covering a range of exploitative practices, including:
– Human trafficking – recruitment, transportation, transfer, harbouring or receipt of individuals through coercion, deception or abuse for the purpose of exploitation.
– Forced labour – work or services performed involuntarily under threat, coercion or intimidation.
– Debt bondage – situations where an individual works to repay a debt under unfair or exploitative conditions.
– Servitude – the obligation to provide services imposed through coercion or abuse.
– Child exploitation – the exploitation of children through labour or other unlawful activities.
The Directors of Educato Limited have overall responsibility for ensuring compliance with this policy and for reviewing its effectiveness.
The Compliance Lead is responsible for:
– Monitoring compliance with this policy and related procedures.
– Investigating concerns and coordinating responses.
– Maintaining appropriate records and evidence.
– Coordinating training and awareness.
– Reviewing procedures in light of legislation, guidance and best practice.
All employees share responsibility for helping to prevent modern slavery and for reporting any concerns.
Educato Limited is committed to ethical and safer‑recruitment practices throughout the candidate journey.
We will:
– Recruit fairly, lawfully and without discrimination.
– Verify identity and right to work documentation before assignments commence.
– Ensure workers enter employment voluntarily, with freedom to leave assignments.
– Provide clear written terms of engagement and transparent information on pay and conditions.
– Prevent exploitative recruitment practices, including the charging of fees to candidates.
Educato Limited does not charge candidates for registration, job‑finding or placement services.
All workers must undergo identity and right to work checks before being supplied for assignments.
Educato Limited will:
– Verify original documentation and, where appropriate, use approved digital checking systems.
– Comply with current Home Office requirements and guidance.
– Maintain accurate records of checks carried out.
Workers who cannot demonstrate a legal right to work in the UK will not be placed on assignment.
We seek to protect workers from exploitation by ensuring:
– Clear assignment information, including role, location, pay and hours.
– Transparent pay arrangements and lawful payment practices.
– Written terms and conditions that the worker can understand.
– Freedom to leave assignments and change employer.
– Access to support where concerns arise.
Educato Limited prohibits:
– Forced labour.
– Withholding of wages.
– Retention of identity documents.
– Unlawful deductions from pay.
– Threats, intimidation or coercion.
Potential indicators of modern slavery may include:
– Reluctance to speak independently, or someone speaking on behalf of a worker.
– Shared bank accounts without a reasonable explanation.
– Lack of personal identification documents.
– Fearful, withdrawn or anxious behaviour.
– Signs of abuse, neglect or poor living conditions.
– Inconsistent employment history or restricted freedom of movement.
These indicators do not prove exploitation, but they must always be treated seriously and escalated in line with this policy.
Educato Limited expects suppliers and partners, including umbrella companies and payroll providers, to uphold equivalent ethical and legal standards.
We may undertake due diligence activities such as:
– Supplier assessments and onboarding checks.
– Compliance reviews and audits.
– Contractual commitments reflecting modern slavery requirements.
– Risk‑based monitoring of higher‑risk suppliers, including overseas providers.
Suppliers are expected to:
– Comply with the Modern Slavery Act 2015 and relevant legislation.
– Operate lawful employment practices and treat workers fairly.
– Pay workers appropriately and transparently.
– Cooperate with reasonable compliance enquiries and audits.
Failure to meet required standards may result in the termination of commercial relationships.
Anyone who suspects modern slavery or exploitation involving a worker, candidate, supplier or any other party connected with Educato Limited is encouraged to report concerns immediately.
Concerns may be reported to:
– Telephone: 0161 804 8860
– Email: info@educato.co.uk
Concerns can also be raised under the Educato Limited Whistleblowing Policy. All reports will be treated seriously and investigated appropriately.
Where appropriate, concerns may also be reported to:
– Modern Slavery Helpline: 0800 0121 700
– Gangmasters and Labour Abuse Authority (GLAA): www.gla.gov.uk
– Police: 101 (or 999 in an emergency)
– Local Safeguarding Partnerships where there are safeguarding concerns relating to children, young people or vulnerable adults.
Individuals who raise concerns in good faith will not be subjected to victimisation, detriment or retaliation.
Educato Limited aims to foster a culture of openness and accountability and encourages staff, workers and suppliers to speak up where they have concerns.
Where modern slavery concerns involve children, young people or vulnerable adults, Educato Limited will follow its Safeguarding and Child Protection Policy and safer‑recruitment procedures immediately.
Concerns may be escalated to Designated Safeguarding Leads, local authorities, the police and other relevant safeguarding agencies as appropriate.
Educato Limited may take the following steps when concerns are raised:
– Gather information and review relevant documentation.
– Conduct interviews with individuals involved.
– Liaise with clients and supply chain partners.
– Seek specialist advice where appropriate.
– Refer concerns to external authorities where required.
Investigations will be conducted proportionately, sensitively and confidentially, with due regard to the safety of those involved.
Relevant personnel receive training covering:
– Modern slavery awareness and indicators.
– Ethical and safer recruitment practices.
– Right to work and identity verification.
– Reporting and escalation procedures.
– Safeguarding considerations.
Training needs are kept under review and training records are maintained.
Educato Limited maintains records relating to:
– Concerns raised and investigations undertaken.
– Supplier assessments and reviews.
– Training activities and completion.
– Compliance checks and audits.
We retain evidence demonstrating compliance with this policy, which may be reviewed during internal audits, client audits, REC audits and procurement exercises.
This policy is reviewed at least annually and sooner where required due to legislative changes, government guidance updates, REC audit recommendations, organisational changes or significant incidents.
This policy should be read alongside the following Educato Limited documents and policies which are available upon request.
– Safeguarding and Child Protection Policy
– Safer Recruitment Policy
– Right to Work Verification Procedure
– Whistleblowing Policy
– Equality, Diversity and Inclusion Policy
– Recruitment of Ex‑Offenders Policy
– Supplier Management Procedure
– Code of Conduct for Agency Workers
